Privacy
Policy
© 2023 Tipsme. All rights reserved.
DATA PRIVACY AND COOKIE POLICY TIPSME
1. IMPORTANT INFORMATION
1.1 TIPSME COMPUTER SOFTWARE TRADING L.L.C is a Company registered in the Emirate of Abu Dhabi, United Arab Emirates with a commercial license no CN-4332861. TIPSME COMPUTER SOFTWARE TRADING operates through a Dubai branch office.
At TIPSME COMPUTER SOFTWARE TRADING L.L.C , and our branch office (collectively referred to as «TipsMe», «we», «us»), we take our data protection and privacy responsibilities seriously. This statement describes how we collect, process, use, disclose and transfer your personal data as a data controller. It covers instances when you contact us, use our services or interact with our websites, such as www.tipsme.ae, and TipsMe mobile app and software. Together, the TipsMe Website, the TipsMe App and the TipsMe Software constitute the «TipsMe Platform».
This Privacy Policy should be read and interpreted together with the Terms of Use of TipsMe.
By accepting our Terms of Use, you are confirming that you have read and understood this Privacy Policy, including all of the provisions on what Personal data we collect and how we use that information. By confirming the use nay services offered by or through TipsMe, you are consenting to the terms in the Privacy Policy.
1.2 By providing us with your data, you warrant to us that you are over 18 years of age.
1.3 Purpose of data processing. We process your data in order to provide you with the TipsMe Platform and all associated services.
1.4 Terms which are not defined in this Privacy Policy shall have the meanings ascribed to them in the Terms of Use of TipsMe:
- User Consent: refers to when you the visitor (hereinafter referred to as «User», «you», «your») access and use any facility or content we own or operate in reference to the TipsMe Platform, which is owned, operated, maintained or mandated under service by TipsMe, you as the User consent to the data practices prescribed in this Privacy Policy. This is further supported in your application for the creation of a User account, if applicable.
- Data Subject: means any person whose confidential and personally identifiable User data is being collected, processed, used, maintained, stored, transferred, disclosed, erased, or destroyed. For ease of understanding: You, as the User of the TipsMe Platform are the Data Subject.
- Data Processor: means any person (other than an employee of the data controller) who processes Personal Data of a Data Subject, on behalf of the Data Controller. Again, we reiterate that TipsMe may process your Personal Data (defined below) directly, or through authorized agents, vendors third parties and service providers of TipsMe, who may be chosen by us for the purposes of furthering the individual and entities’ business of TipsMe.
- Data Controller: means a person who (either alone or jointly with other persons) determines the purposes for and the manner in which any Personal Data is to be processed. TipsMe is the data controller of your Personal Data as well as the Data Processor. Data protection is important to us and we adhere to all applicable data protection laws and regulations globally for the purposes mentioned in this policy and only as applicable.
- We may also process your Personal Data and you consent to the processing thereof, to satisfy all legal obligations, if it is necessary to carry out any obligations arising from any contracts entered into with you or to carry out any services to you, by any TipsMe entity, or to take steps at your request prior to entering into a contract with you, or for our legitimate interests to protect our property, rights or safety of either TipsMe entity, it’s Users, customers, clients, other persons or other entities.
- We have also appointed a Data Protection Officer (“DPO”), together acting as a designated Data Protection Controller, who shall be responsible for overseeing data-related matters to address any questions in relation to this Privacy Policy. If you have any questions about the Privacy Policy, including requests to exercise your rights related to data, please contact us: support@tipsme.ae
1.5 Updates. We may amend this Private Policy from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this statement. If we make material changes to this Privacy Policy, we will seek to inform you by notice on our website or email («Notice of Change»).
1.6 Third Party Websites or apps. TipsMe Platform may link you to other websites or apps. We are not responsible for the way in which third party websites or apps operate or the way in which they may process any personal data, which you provide to them. It is important that you understand this and check their respective privacy policies and terms of use.
2. TYPES OF DATA COLLECTED AND PROCESSED
2.1 All credit/debit cards details and personally identifiable information will NOT be stored, sold, shared, rented or leased to any third parties.
The Website Policies and Terms & Conditions may be changed or updated occasionally to meet the requirements and standards.
Therefore the Customers’ are encouraged to frequently visit these sections in order to be updated about the changes on the website. Modifications will be effective on the day they are posted.
TipsMe collects Personal Data and Anonymous Data of Data Subjects; and only in a manner as described below:
(a) Personal Data means data that allows:
- someone to identify or contact you, including, for example: your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data, in certain circumstances, your photograph;
- data relating to any payments you make or receive using the Payment Processors associated with the TipsMe Platform (such as the amount, date and recipient of payments); and
- contact details optionally provided by Customers when submitting reviews.
TipsMe processes this data to enable you to access and use the TipsMe Platform, to keep records of any payments you make or receive, and to enable follow-up on Customer reviews by the Users who use the TipsMe Platform. TipsMe’s lawful ground for this processing is the provision (or prospective provision) of services to you.
(b) Anonymous Data means data that is not associated with or linked to your Personal Data: data about the User session - the sequence of requests made by the Tip Payer during the use of the Service) obtained when accessing the Service using Internet statistical services (Yandex.Metrika, Google Analytics, Amplitude, etc.) for the purpose of collecting analytical data to improve and refine the Service. Anonymous Data (i.e. encrypted data) does not, by itself, permit the identification of individual persons.
(c) Communication Data includes any communications that you send to TipsMe, whether through the contact form on our website, via email, text message, social media messaging, social media posting or by any other means. TipsMe processes this data for the purposes of communicating with you. We also process it to keep records and to establish, pursue or defend legal claims. TipsMe’s lawful ground for this type of processing is our legitimate interest in replying to communications we receive, keeping records, and establishing, pursuing or defending legal claims.
(d) Usage Data includes data about how you use the TipsMe Platform together with any data that you post on the TipsMe Platform, including any reviews. TipsMe processes this data to operate the TipsMe Platform and to make sure that appropriate content is provided to you. TipsMe also processes this date to ensure the security of the TipsMe Platform, to maintain back-ups of information and to enable the publication and administration of the TipsMe Platform. TipsMe’s lawful ground for such processing is our legitimate interest in enabling the proper administer of the TipsMe Platform and our business.
(e) Technical Data includes data about your use of the TipsMe Platform, and includes:
- your IP address, log-in details, and browser details;
- the duration, number and frequency of your visits to TipsMe Website pages and the TipsMe App, and your page views and navigation paths; and
- time zone settings and other details regarding the devices with which you access the TipsMe Platform.
This Technical data is produced by an analytics tracking system. TipsMe processes this data to analyse your use of the TipsMe Platform, to administer the TipsMe Platform and our business, to deliver website content and advertisements to you, and to analyse the effectiveness of our advertising. TipsMe’s lawful ground for processing this type of data is our legitimate interests to enable the proper administration of the TipsMe Platform and to develop our business and marketing strategies.
(f) Please note that: TIPSME DOES NOT COLLECT ANY SENSITIVE DATA ABOUT YOU. Sensitive Data is data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, membership in trade unions, and health, or genetic and biometric data.
(g) Information which may be further required from you: We may need to request specific information from you to help us to confirm and verify your identity, so as to ensure that your rights to access your Personal Data or to exercise any of your other rights, as determined by contract, the law or otherwise. This is a security measure to ensure that Personal Data is not disclosed to any authorised person, who has no right to receive it. We may also contact you to ask you for further information in relation to your request, in order to speed up our response to any request received from you, when you exercise your rights.
2.2 If you fail, neglect and/or refuse to provide us with your Personal Data: Where we need to collect Personal Data by law, or under TipsMe’s Terms and Conditions, in contracting with you and if you fail to provide that data when requested, we may not be able to perform the services. In this case, TipsMe shall have the right to discontinue the User Services and/or may close your User account, however, we will notify you if this is the case at the time.
2.3 Be advised that in usage of our Platform, you consent to the following:
- We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, date of birth, government issued identification, (including but not limited to address, employment, city name, etc.)
- We may collect financial information, including, without limitation, financial statements, digital wallet account, information concerning the entitlement to tips, employment status, working hours, information related to the payment of tips owing to you or paid to you.
- We may also collect other Personal Data supplied by third-party entities (including Governmental authorised or mandated entities) and service providers/agents in the outsourcing of services, including, but not limited to third party identity verification services.
- If you tell us where you are (i.e. by allowing any of your devices, mobile device or computer to send us your geo-location), we may store that information.
- Certain services, such as two-factor authentication may require collection, use, processing, transfer and storage of your phone number and possibly other data. We may associate that phone number to your mobile device identification information.
- If you provide us feedback or contact us, we will collect your name and e-mail address, as well as any other content included in form in which it was received (i.e. the details and content of an email), in order to send you a reply or in to contact you.
- We also collect other types of Personal Data that you voluntarily provide to us when contacting us – i.e. in seeking support services via email, or calling us via the contact center, support chat room, or other information provided to support services staff.
- We may collect other data, including but not limited to referral Uniform Resource Locators (URLs), your location and analytics information related to the usage of our Facilities.
- Some information is collected automatically by our Platform, including, but not limited to our websites, application, platform, networks and servers:
• Our servers (which may be hosted by a third-party service provider) collect information from you automatically, including your browser type, Internet service provider (ISP), referring/exit pages, operating system, Internet Protocol (IP) address, domain name, and/or a date and time stamp for your visit to our Facilities, as well as clickstream data.
• We use Cookies to collect information. Cookies are selected pieces of information that a website or platform (included as our facilities) sends to your device or computer’s hard drive, while you are viewing or using our Platform. For more information, please see our Cookie Policy at Article 8.
• We retain information on your behalf, including tips payers data, transactional data and other session data, linked to your User account.
2.4 TipsMe will only use your Personal Data for the purpose for which it was originally collected or, if necessary, if the purpose of Processing is similar or close to the purpose for which such data is collected. If TipsMe is required to use your Personal Data for a new and unrelated new purpose, TipsMe will inform you of the grounds for this use.
2.5 TipsMe may collect data about you when you provide the data directly to us (for example, by completing a form on the TipsMe Platform, by opening an account, by sending us emails or messages, or by providing us with feedback).
TipsMe may receive data about you from third parties such as analytics providers, advertising networks and search information providers based outside of the UAE, and from providers of payment and technical services.
2.6 Data Retention. TipsMe adheres to all applicable legislative provisions and Data Protection laws of UAE; hence TipsMe shall retain and store a written Record of Processing Activities (“ROPA”) of how it processes all User specific data as recommended by the regulations. Such a ROPA shall include the purpose of our processing, what data types we process, the different parties who are recipients of such Personal Data, time limits of retention of Personal Data and a description of our security measures. Should any further information be required, please contact us at support@tipsme.ae
2.7 Data protection impact assessment. In adhering to all applicable legislative provisions and data protection laws of UAE, TipsMe may carry out an assessment of the impact of the proposed processing operations on the protection of User Personal Data, considering the risks to your rights (“DPIA”). In accounting for the protection of commercial interests we shall seek a User’s input on the intended processing, if and where applicable. The outcome of such DPIA’s may result in the alteration and update of this Privacy Policy, at which point, we shall notify you. Should any further information be required, please contact us at support@tipsme.ae
3. DATA SUBJECT RIGHTS
3.1 Under data protection laws you have rights in relation to your Personal Data, including the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
More information about these rights is available at Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (United Arab Emirates)
If you wish to exercise any of your rights, please email TipsMe at the email address set out in Section 1 above.
3.2 You will not be charged any fee to access your Personal Data (or to exercise any of the other rights). However, TipsMe may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. TipsMe may also refuse to comply with your request in these circumstances.
3.3 TipsMe endeavours to respond to all legitimate requests without undue delay and within one (1) month calendar of receipt of any request from you. Occasionally it may take us longer than one (1) month if your request is particularly complex, or if you have made duplicated or numerous requests, but it shall in no scenario take us more than three (3) calendar months to respond to your legitimate data access requests. In this case, we will notify you of receipt of such request(s) and keep you updated as to the status of progress concerning such request(s).
4. DISCLOSURES OF YOUR PERSONAL DATA
4.1 We may share your Personal Data in accordance with this Privacy Policy, for the purposes described in Section 2, or as required or authorized by applicable law. Your Personal Data may be shared:
(a) with non-affiliated third parties to perform services for or functions on TipsMe’s behalf such as marketing our products or services, performing payment transactions or maintaining or improving our services or administering our working relationship with you, provided we have an applicable written agreement with the non-affiliated third party. Examples would include entities such as security providers, analytics or research companies, identity verification or fraud prevention companies, payment card associations, payment networks, payment processors, and other entities needed to facilitate our delivery of our services to you;
(b) with professional service providers and advisors who perform functions on our behalf, such as lawyers, accountants and auditors;
(c) with government regulatory authorities and other organizations (such as the police, tax authorities, or other law enforcement agents) as requested by such authorities and organizations or as required or authorized by law or other regulatory requirements in jurisdictions in which we operate;
(d) in connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of our business;
(f) in the future with affiliates and non-affiliated third parties in connection with a marketing campaign for their products or services from which you will have the right to opt out;
(g) as we deem reasonably necessary to protect our services, comply with applicable laws, rules and regulations, and to protect us, our services and the public from fraud, harm, security breaches, and other potentially prohibited or illegal activity; and
(h) with affiliates for the purposes described herein.
4.2 In the case of Data Subject using the TipsMe Platform to connect to a Payment Processor to receive payments of tips via such Payment Processor, TipsMe may be required to share Personal Data with your employer or accountants and other professionals working on your employer's behalf for the purposes of:
- verifying your employment; and
- enabling such persons to operate tips procedures. TipsMe may also share Personal Data with such employers for the purposes of implementing schemes for the pooling of tips.
4.3 TipsMe’s Platform or communications may contain links to other third-party websites which are not owned or operated by TipsMe and too, which are regulated by their own privacy policies. If you click on a third-party link, you will be directed to that third party’s site. TipsMe strongly advises you to review the privacy policy of every site you visit. TipsMe is not responsible for the privacy policies of these third-party websites, regardless as to whether they were accessed using the links from our facilities. TipsMe has no control over and assumes no liability for the content, privacy policies or practices of any third-party sites or services.
4.4 TipsMe specifically herein mandates that you, as the User (as per this Privacy Policy) to visit, familiarize, understand the below entity policies, being partners of TipsMe in providing services under the facilities to you, however – even if not done as mandated herein, you as the User accepts that through the application for the creation of a User account, the terms of their individual privacy policies, cookies policies, as well as terms and conditions, as third-party service providers to TipsMe (albeit, not to be construed as a closed list) and too which should include all third party vendors:
PayIT: https://payit.ae/privacypolicy/
Stripe: https://stripe.com/privacy
Be advised: Other than as stated in this Privacy Policy, TipsMe does not disclose any of your personal information to any third parties, unless required to do so by law enforcement, court order, or in compliance with legal reporting obligations.
5. DATA STORAGE AND SECURITY
5.1 The security of your Personal Data is important to us. We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and after it is received. Any of your information stored on our computer systems is protected by safeguards including physical, technical (data encryption) and procedural methods. No method of transmission over the internet or electronic storage is completely secure. Consequently, we cannot guarantee 100% security.
5.2 While you are a user of TipsMe’s Platform and thereafter, we will store your Personal Data only for as long as is reasonably necessary, taking into consideration our relationship with you, our service providers’ relationships with you, the purposes stated in this Privacy Policy, our need to resolve disputes or claims or assist with investigations, and our need to respond to requests for such information from government regulatory authorities and other organizations, or otherwise comply with legal and regulatory requirements under applicable law.
5.3 User Personal Data is stored and transferred in compliance with the applicable legislation or regulations of UAE.
We store and process your Personal Data in data centers located UAE, and we comply with the data protection regulations of these jurisdiction insofar as they apply to TipsMe.
5.4 If TipsMe transfers your data to third parties outside of the UAE, we will ensure that certain safeguards are in place of security for your Personal Data. Therefore:
- TipsMe may transfer your Personal Data to countries that the European Commission have approved as providing an adequate level of protection for Personal Data; or
- Where TipsMe uses certain service providers who are established outside of the UAE, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give Personal Data the same protection it has in Europe.
If none of the above safeguards is available, TipsMe may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please contact us at support@tipsme.ae if you want further information on the specific mechanism used by us when transferring your Personal Data.
6. HOW TO UPDATE YOUR PERSONAL DATA
6.1 Whenever possible, you can update your Personal Data directly within your User account settings section, subject to verification by TipsMe. If you are unable to change your Personal Data, please contact us to make the required changes.
6.2 If you wish for TipsMe to update your information, please contact us in making such a request.
6.3 We will retain your information for as long as may be needed to provide you access to your User account and or Services of TipsMe, or for a reasonable period after you close your User account with TipsMe.
6.4 If you wish to close your User account, you can do so from your User account setting session or you can contact us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms and Conditions.
7. SECURITY PRECAUTION EXERCISED BY TIPSME FOR PROTECTION OF YOUR DATA
7.1 We take the protection of your personal information seriously and in so doing, we use industry-standard data encryption technology and have implemented restrictions related to the storage of and the ability to access your personal information.
7.2 All your personal information and sensitive data is stored in servers located within the country.
7.3 TipsMe’s Platform are scanned on a regular basis for security holes and known vulnerabilities, in order to best ensure its security.
7.4 Your Personal Data is contained behind secured networks and is only accessible by a limited number of individuals who have special access rights to such systems and are required to keep the information confidential.
7.5 Please note that no transmission over the Internet or any method of electronic storage can be guaranteed to be absolutely 100% secure, however, our best endeavours will be made to secure data and the ability to access your personal information.
7.6 Without prejudice to our efforts on protection of your Personal Data, nothing contained in this Privacy Policy constitutes a warranty of security of the facilities, and you agree to transmit data at your own risk. Please note, that TipsMe and the facilities do not guarantee that your data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
7.7 We would like to draw your attention on the fact that TipsMe will never send you email or SMS or call you to ask for financial or payment information, such as your credit card number, passcode, User account number or pin number, in an e-mail, text or any other communication that we send to you. Please, always check that any website on which you are asked for financial or payment information in relation to our reservations or services is in fact legitimately owned or operated by TipsMe. The risk of impersonating hackers exists and should be taken into account when using our Platform.
7.8 If you do receive any suspicious communication of any kind or request, do not provide your information and report it us by contacting our offices immediately. Please also immediately notify us if you become aware of any unauthorised access to or use of your User account.
7.9 Since we cannot guarantee against any loss, misuse, unauthorised acquisition, or alteration of your data, please accept that you play a vital role in protecting your own Personal Data, including the adoption of sufficient safety measures such as your choosing of an appropriate password of sufficient length and complexity and to not reveal this password to any third-parties.
7.10 Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us, or receive from us by Internet or wireless connection, including: email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. You can contact us if you have reason to believe that your data is no longer secure.
7.11 Lastly, please note that should the security of your Personal Data be breached and the security of your rights be at high risk, we shall promptly and immediately communicate to you the nature of the breach which has taken place, the likely consequences of such a breach and shall describe thoroughly the measures we have implemented to address the breach and to mitigate any and all adverse effects to you and your rights. In the unlikely event of a breach occurring, please reach out to our DPO at support@tipsme.ae for further information and for further advise on how to mitigate the potential adverse effects of such a breach.
8. COOKIE POLICY
8.1 You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the TipsMe Platform may become inaccessible or not function properly.
8.2 What is a Cookie
8.2.1 A “Cookie” is a small piece of encrypted text saved on the browser or hard drive in your computer or mobile device when you visit a website. Cookies are selected pieces of information that a websites or platform (included as our facilities) sends to your device or computer’s hard drive, while you are viewing or using our Facilities, as permissioned. It allows us to recognise you and make your next visit easier and the experience of the TipsMe Platform more useful to you. Cookies can be stored for varying lengths of time on your browser or device.
8.2.2 We use both session/transient Cookies (which expire once you close your device web browser) and persistent Cookies (which stay on your computer until you delete them) to collect information in order to provide you with a more personal and interactive experience in using our Platform. This type of information is collected to make our Platform more useful to you and to tailor the experience with us to meet your special interests and needs. Cookies work to make your experience browsing our sites as smooth as possible and they remember your preferences, so you don’t have to insert your details again and again.
8.2.3 Be advised that: The cookie file is set on a particular browser on a particular device, so when you use a different device, that cookie will not exist.
8.2.4 Cookies cannot be used to obtain data from your hard drive, get your e-mail address or steal sensitive or personal information about you and computer viruses are not passed through the setting or use of cookies. The only way that any private information could be part of your Cookie file would be if you personally gave that information to a web server. Also, each Cookie can only be read by the server that set it, so strange servers cannot view or steal the information in a cookie that you have previously accepted.
8.3 How TipsMe uses Cookies?
When you use and access the TipsMe Platform, we may place a number of Cookies on your device’s web browser. We use Cookies to enable certain functions of the websites i.e. to provide analytics, to prevent fraudulent or illegal activity, to store your preferences, to enable advertisements delivery, including behavioral advertising. We also use Cookies to enhance your browsing experience by:
- Recognizing when you log in and any preferred settings.
- Giving you a browsing experience that is unique to you and to serve you content which we believe improves your sites experience.
Analysing how you use our Facilities which helps us to troubleshoot any problems and to monitor our own performance.
8.4. What Cookies do we use?
TipsMe uses the following four type of cookies,
Essential Cookies: are essential to let you move around the websites or mobile application and use its features, such as accessing secure areas of the Facilities. These Cookies allow our mobile application to provide services at your request. TipsMe uses essential Cookies to authenticate users and prevent fraudulent use of User accounts.
Performance Cookies: may be used to collect information about how you use YAP, for instance, which pages you visit most often, and if you experience any error messages. They also allow us to update our websites and mobile application to improve performance and tailor it to your preferences. These Cookies do not collect any information that could identify you – all the information collected is anonymous.
Functionality Cookies: are used to remember the choices you make, e.g. your username, log in details and language preferences. They also remember any customizations you make to give you enhanced, more personal features of your TipsMe experience.
9. Contacting Us
If you have any questions about our Privacy Policy as outlined above, or if you have any complaints, please contact us at support@tipsme.ae
The current version of the Policy can be found at: https://tipsme.ae/
10. Governing Law and Jurisdiction
Any purchase, dispute or claim arising out of or in connection with this website shall be governed and construed in accordance with the laws of UAE.